The ongoing shortage of behavioral health clinicians across the United States has made accessing care challenging for millions of people, especially Medicare beneficiaries. Medicare’s proposed 2023 Physician Fee Schedule, introduced on July 7, aims to improve Medicare behavioral health care access by expanding the range of providers who can serve Medicare members. This move could set a precedent for other health insurers, as Medicare’s policies often influence the broader health care market.
Medicare covers about 64 million Americans, mostly aged 65 and older, and accounted for 22% of U.S. health care spending in fiscal year 2021. Because Medicare holds such a significant role, changes to Medicare behavioral health care have the potential to impact how services are delivered nationwide. Vatsala Kapur of Bamboo Health explained, “Medicare sets the tone for every other payer. When Medicare takes that lead, it sends a lot of positive signals to the market, to other payers.”
Loosening Supervision to Expand Behavioral Health Provider Access
A key part of the proposed Physician Fee Schedule is reducing supervision requirements for several behavioral health practitioners, including licensed professional counselors, marriage and family therapists, addiction counselors, and peer recovery specialists. Under the new rule, Medicare behavioral health care services provided by these professionals would require only “general” supervision, rather than “direct” supervision, meaning the supervising clinician would not need to be physically present on-site.
This change makes it easier for beneficiaries to access behavioral health care providers and could help reduce wait times and increase service availability. Judy Waltz, a healthcare attorney, noted, “It may not look like such a big thing to the rest of the world but it’s a big step for them.” Dr. Lori Ryland from Pinnacle Treatment Centers added, “These services can safely be provided without a physician or nurse practitioner in the building. General supervision can adequately support the behavioral health services while improving availability and access.”
Addressing the Behavioral Health Clinician Shortage
With nearly 53 million adults reporting mental illness in 2020 and 31% of those individuals reporting unmet care needs, Medicare behavioral health care access improvements are critical. Furthermore, over 130 million Americans live in mental health clinician shortage areas, highlighting the pressing demand for more accessible care.
However, the proposed rule does not allow these newly supervised providers to bill Medicare independently. Instead, their services will still be billed under the supervising provider’s name, maintaining certain regulatory standards. Waltz emphasized that general supervision requires strong communication and coordination: “The doctor should be looking at the notes every time the LMFT is seeing the patient,” she said.
One persistent barrier to care coordination is low adoption of electronic health records in behavioral health; only 6% of behavioral health facilities use EHRs. Vatsala Kapur suggested that “the federal government and the Medicare program specifically can play a leadership role in funding technology to support and advance care coordination because, right now, it is inadequate.”
Expanding Addiction Treatment and Telehealth under Medicare
The rule also enhances Medicare behavioral health care by supporting opioid treatment programs (OTPs), including mobile units that provide medication-assisted treatment (MAT) such as methadone or buprenorphine. These mobile services can now bill Medicare without separate registrations for the mobile unit, removing logistical barriers to treatment.
Dr. Ryland pointed out the importance of this access: “MAT requires regular appointments with a physician or frequent clinic visits, which can be a barrier for patients without reliable transportation.” Increased Medicare payments for telehealth initiation of buprenorphine MAT further improve access to comprehensive addiction treatment.
In addition, telehealth flexibilities put in place during the COVID-19 public health emergency will continue for 151 days after its official end, allowing mental health services for Medicare beneficiaries to be delivered remotely from home without an in-person visit.
Integrating Behavioral Health with Primary Care
CMS is also proposing to reimburse clinical psychologists and licensed clinical social workers providing behavioral health care as part of primary care teams. This supports the growing movement toward integrated care, which brings behavioral health services into primary care settings to better address patients’ holistic health needs.
Kapur noted, “Allowing behavioral health practitioners to get compensated to participate with the primary care provider team is going to help really move the ball on that.” Since 2017, Medicare has reimbursed behavioral health integration (BHI) services separately. The new rule expands who can lead BHI and streamlines access by allowing psychiatric diagnostic evaluations to initiate services.
Medicare’s proposed 2023 Physician Fee Schedule represents a critical opportunity to enhance Medicare behavioral health care access by broadening provider roles, supporting addiction treatment innovations, extending telehealth services, and promoting integrated care. Given Medicare’s influence in the health care system, these changes could prompt widespread improvements across payers and ultimately increase access to quality behavioral health care for millions of Americans.
